Guide to Cross-Border Battery Shipping: Top 10 Key Considerations and Analysis of Embargoed Countries

I. Preface: Cross-Border Battery Shipping – Compliance Is the “Lifeline”, Risk Prevention Is Imperative

With the globalization of the new energy industry and consumer electronics market, demand for cross-border battery shipping has grown annually. However, battery-related goods (including lithium-ion batteries, lead-acid batteries, button batteries, etc.) are classified as “Class 9 Dangerous Goods” by international transportation organizations due to their “flammable, explosive, and corrosive” properties. They are subject to triple strict supervision under the United Nations Recommendations on the Transport of Dangerous Goods (TDG), the International Air Transport Association (IATA) Dangerous Goods Regulations (DGR), and the International Maritime Organization (IMO) International Maritime Dangerous Goods Code (IMDG Code).

According to 2024 data from IATA, there are over 300 logistics accidents worldwide each year caused by non-compliant battery shipping. Among these, “short-circuit fires due to damaged packaging” and “detention by customs due to missing certification documents” account for more than 80%, with an average direct loss of over $500,000 per accident. Enterprises may also face heavy fines from the destination country (e.g., the EU imposes a maximum fine of three times the value of the goods). Furthermore, policies on battery imports vary significantly across countries, and some have imposed direct “embargoes” for safety or environmental reasons. If enterprises overlook policy details, they may easily fall into predicaments such as “cargo detention and fund freezing”.

This article breaks down the compliance key points of cross-border battery shipping from two dimensions – the “Top 10 Key Considerations” (covering the entire process from packaging and certification to declaration) and “Analysis of Key Embargoed Countries” (including policy bases and exemption conditions) – to help enterprises avoid risks and achieve safe and efficient transportation.

II. Top 10 Key Considerations for Cross-Border Battery Shipping: No Mistakes Allowed at Any Step from Packaging to Customs Clearance

Compliance in cross-border battery shipping runs through the entire chain of “pre-transportation preparation, in-transit monitoring, and destination customs clearance”. It is necessary to strictly follow international rules and destination country requirements. The following 10 key considerations are crucial for risk avoidance:

(1) Consideration 1: Clarify Battery Classification and Match Corresponding Transportation Standards

Different types of batteries have significantly different applicable transportation rules and packaging requirements due to varying risk levels. Enterprises must first complete “battery classification” to avoid compliance failures caused by misclassification:

• Classification by Chemical Properties:
• Lithium Batteries (including lithium-ion batteries and lithium metal batteries): The most common and strictly regulated type. It is necessary to distinguish between “batteries shipped individually” (e.g., battery cells) and “equipment containing batteries” (e.g., mobile phones, laptops). The former has a higher risk level and requires additional “short-circuit prevention and extrusion prevention” requirements;
• Lead-Acid Batteries: Contain corrosive electrolytes and are classified as “corrosive dangerous goods”. They must be packaged separately with “leak-proof labels” and are prohibited from being shipped in the same container as food or electronic equipment;
• Button Batteries: Mostly lithium metal batteries. Small in size but easily overlooked, the number of button batteries per carton must not exceed 100, and they must be separated by “anti-static trays” to prevent friction-induced fires;
• Classification by Transportation Method:

Air transportation has the strictest restrictions on batteries (e.g., the lithium content of a single lithium metal battery cell must not exceed 2g), while sea transportation restrictions are relatively lenient (e.g., the energy of a single lithium-ion battery pack can be relaxed to 100Wh). Road transportation must comply with the Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR). For example, the EU requires road transport vehicles carrying batteries to be equipped with “fire-fighting devices”.

Error Case: An enterprise declared “individually shipped lithium-ion batteries” as “equipment containing batteries”. After being discovered during airline security checks, the cargo was detained, and the enterprise was fined $12,000 (in accordance with Chapter 9.4 of the IATA DGR).

(2) Consideration 2: Complete UN38.3 Testing and Obtain an Official Report

UN38.3 testing is the “basic threshold” for cross-border battery shipping. Specified in the UN Manual of Tests and Criteria, it is used to verify the safety of batteries under extreme conditions such as “high and low temperatures, vibration, impact, and short circuits”. All batteries for cross-border shipping (including equipment containing batteries) must provide a “UN38.3 Test Report”; otherwise, carriage will be refused:

• Test Content: There are 8 mandatory tests, including altitude simulation, thermal testing, vibration testing, impact testing, external short circuit testing, crush testing, overcharge testing, and forced discharge testing. The report must be issued by an “ISO 17025-accredited laboratory” (e.g., SGS, Intertek, TÜV) and is valid for 1 year;
• Special Requirements:
• Lithium metal batteries require an additional “lithium content test” to ensure the lithium content of a single cell does not exceed 1g and that of a single battery pack does not exceed 2g;
• For lithium batteries used in air transportation, the “battery energy (Wh)” must be clearly stated in the UN38.3 report. The energy calculation formula is “capacity (Ah) × voltage (V)”. For example, 10Ah × 3.7V = 37Wh. Lithium batteries with energy exceeding 100Wh are prohibited from air transportation (equipment containing batteries can be relaxed to 160Wh, but prior approval from the airline is required).

Compliance Tip: The UN38.3 report must include information such as “battery model, production batch, and testing laboratory qualification”. Copies must be stamped with the enterprise’s official seal and submitted together with the commercial invoice and packing list during customs clearance.

(3) Consideration 3: Packaging Must Meet the Triple Requirements of “Short-Circuit Prevention, Leakage Prevention, and Extrusion Prevention”

Battery packaging is key to preventing safety accidents during transportation. Corresponding packaging standards must be matched according to battery types, with core requirements including “short-circuit prevention, leakage prevention, and extrusion prevention”:

• Short-Circuit Prevention Measures:

Lithium batteries shipped individually must have their electrodes covered with “insulating materials” (e.g., PVC insulating sleeves) or be placed in “short-circuit prevention packaging boxes” (with internal grooves to fix cells and avoid electrode contact). Batteries are prohibited from being shipped loose in cartons to prevent short-circuit fires caused by electrode collision;

• Leakage Prevention Measures:

Batteries containing electrolytes, such as lead-acid batteries and nickel-metal hydride batteries, must be packaged in “sealed plastic containers” with a thickness ≥ 0.5mm. “Absorbent cotton” (with an area ≥ 1.5 times the base area of the container) must be placed at the bottom of the container to prevent electrolyte leakage from contaminating other goods;

• Extrusion Prevention Measures:

Lithium battery packs must be wrapped with “foam cushioning pads” with a thickness ≥ 5cm, and the loading weight per carton must not exceed 20kg to avoid battery deformation caused by extrusion during transportation. For equipment containing batteries, the device switch must be set to the “off state”, and the edges of the device must be wrapped with “bubble wrap” to prevent accidental button presses from causing power consumption during startup.

International Standards: Sea transportation packaging must comply with Chapter 3.4 of the IMDG Code, and air transportation packaging must comply with Chapter 6.2 of the IATA DGR. For example, lithium battery packaging for air transportation must be marked with “Cargo Aircraft Only” (for passenger aircraft transportation, additional compliance with “battery energy ≤ 100Wh” is required).

(4) Consideration 4: Correctly Attach Dangerous Goods Labels and Marks, Ensuring Prominent Placement

Packaging for cross-border battery shipping must be affixed with three types of marks: “dangerous goods labels, operation labels, and warning signs”. Their placement must be prominent to facilitate security checks and identification during transportation:

• Dangerous Goods Labels:

Lithium batteries must be affixed with “Class 9 Dangerous Goods Labels” (white background, black pattern, size ≥ 10cm × 10cm), and lead-acid batteries must be affixed with “Corrosive Dangerous Goods Labels” (orange background, black pattern). Labels must be attached to the “front and sides” of the packaging, ≥ 5cm from the packaging edges, and must not cover other information;

• Operation Labels:

Lithium batteries shipped individually must be affixed with “Short-Circuit Prevention Labels” (marked with “Battery – No Short Circuit”), and equipment containing batteries must be affixed with “Equipment Contains Batteries Labels” (marked with “Contains Lithium Batteries”). Batteries for air transportation must be affixed with “Cargo Aircraft Only Labels” (if prohibited on passenger aircraft);

• Warning Signs:

The packaging must be marked with an “upright sign” (upward arrow, red font) to prevent electrolyte leakage caused by inversion during transportation (e.g., for lead-acid batteries). A “No Open Flame” sign must also be marked to remind operators to keep away from fire sources.

Compliance Check: Labels must be made of “waterproof materials” to avoid blurring due to moisture during transportation. For example, an enterprise’s labels were soaked by rain and became unrecognizable during customs clearance in Germany, resulting in the cargo being detained for 3 days and incurring port detention fees of 800 Euros.

(5) Consideration 5: Accurately Declare Cargo Information, Prohibiting “Under-Declaration and Misdeclaration”

The “authenticity of declarations” for cross-border battery shipping is a key focus of customs supervision. Enterprises must accurately fill in battery information in commercial invoices, packing lists, and waybills, and are prohibited from “under-declaring value” or “misdeclaring cargo nature”:

• Declaration Content:

It is necessary to clearly mark the “cargo name (e.g., ‘Lithium Ion Batteries, UN3480’)”, “battery model”, “quantity”, “energy (Wh)”, and “UN number” (e.g., UN3480 for lithium-ion batteries, UN3090 for lithium metal batteries, UN3481 for equipment containing batteries). The amount on the commercial invoice must be consistent with the actual value of the goods, with an error not exceeding 5%;

• Prohibited Behaviors:

“Lithium batteries” must not be declared as “ordinary electronic product accessories”, and “individually shipped batteries” must not be declared as “equipment containing batteries”. For example, an enterprise misdeclared UN3480 lithium batteries as “mobile phone accessories”. After being seized by UK Customs, the cargo was confiscated, and the enterprise was included in the “customs blacklist”, prohibited from exporting goods to the UK for 1 year;

• Special Declarations:

Batteries shipped to the EU require an additional “Battery Passport” declaration (in accordance with the EU’s New Battery Regulation, effective June 2024), which includes the battery’s “production information, recycling information, and carbon footprint”. Failure to declare will result in customs clearance refusal.

(6) Consideration 6: Select Freight Forwarders and Carriers with Dangerous Goods Transportation Qualifications

Cross-border battery shipping must be entrusted to “freight forwarders and carriers with dangerous goods transportation qualifications”; otherwise, the cargo may fail to be shipped normally and even face legal liability:

• Freight Forwarder Qualification Requirements:

It is necessary to select freight forwarders “with dangerous goods transportation filing qualifications” (e.g., in China, obtaining the Road Dangerous Goods Transportation Permit; in the EU, obtaining ADR qualifications). Freight forwarders must be familiar with the “dangerous goods rules for different transportation methods” and be able to assist enterprises in preparing certification documents (e.g., UN38.3 reports, dangerous goods transportation identification certificates);

• Carrier Qualification Requirements:

Airlines must have the “IATA Dangerous Goods Transportation Permit” (e.g., Air China, United Airlines), shipping companies must have “IMDG Code compliance qualifications” (e.g., Maersk, COSCO Shipping), and road carriers must be equipped with “specialized dangerous goods transportation vehicles” (e.g., trucks with “dangerous goods signs”, equipped with fire extinguishers and leakage prevention tools in the vehicle);

Pitfall Avoidance Tip: Avoid selecting “small unqualified freight forwarders”. Such freight forwarders often transport batteries through “misdeclaration”. Once seized, the enterprise must bear full responsibility (including fines and cargo losses). An enterprise once entrusted an unqualified freight forwarder to transport lithium batteries; the cargo was detained at Hong Kong Airport. In the end, not only could the cargo not be retrieved, but the enterprise also had to pay a fine of $30,000.

(7) Consideration 7: Understand the Destination Country’s Import License Requirements in Advance to Avoid “Detention Due to Lack of License”

Some countries implement “license management” for battery imports, requiring advance application for official license documents; otherwise, the cargo will be detained by customs upon arrival:

• Typical Country Requirements:
• United States: It is necessary to apply to the U.S. Department of Transportation (DOT) for a “Dangerous Goods Import License” in advance and submit a “Battery Safety Declaration” to U.S. Customs and Border Protection (CBP). The declaration content includes “compliance with UN38.3 standards and no mixed dangerous goods”;
• Japan: It is necessary to apply to Japan’s Ministry of Economy, Trade and Industry (METI) for “battery import filing”. During filing, a UN38.3 report and JIS certification (for lithium batteries) must be provided, with a filing cycle of approximately 5-7 working days;
• Brazil: It is necessary to apply to Brazil’s National Institute of Metrology, Standardization and Industrial Quality (INMETRO) for a “Product Conformity Certificate”. Lithium batteries require additional compliance with the “IEC 62133 test”; otherwise, customs clearance will be refused;
• License Document Validity:

Import licenses in most countries are valid for 1 year, and transportation must be completed within the validity period. If the license expires, a re-application is required. For example, an enterprise used an expired “Japan Battery Import Filing Document”; the cargo was detained after arriving at Yokohama Port. Re-application took 10 days, causing the enterprise to miss the sales peak and suffer losses exceeding 800,000 Yen.

(8) Consideration 8: Real-Time Monitoring of Cargo Status During Transportation to Prevent Sudden Risks

Batteries may cause safety accidents during transportation due to “excessive temperature or packaging damage”. Real-time tracking of cargo status through “technical means + manual monitoring” is required:

• Technical Monitoring:

For high-value or large-batch battery transportation, “temperature and humidity sensors” and “vibration sensors” must be installed. Sensor data can be transmitted to a cloud platform in real time. When the temperature exceeds 60℃ or the vibration amplitude exceeds 5G, the system will automatically alarm to facilitate timely measures (e.g., adjusting the transportation route, emergency unloading);

• Manual Monitoring:

During road transportation, drivers must be required to inspect the cargo packaging every 2 hours (e.g., for damage or leakage). During sea transportation, the carrier must be entrusted to regularly inspect the internal status of the container. During air transportation, it is necessary to confirm the “cargo loading position” with the airline in advance (avoiding placement in the same cabin as heat sources or heavy objects);

Emergency Handling: If battery packaging damage or leakage is found during transportation, the cargo must be immediately moved to a “safe area” (away from fire sources and crowds), and the local fire department and dangerous goods disposal agency must be contacted. Self-disassembly or disposal is prohibited (in accordance with the “Emergency Measures” requirements in Chapter 1.4 of the TDG).

(9) Consideration 9: Prepare Complete Documents for Destination Customs Clearance – None Can Be Missing

Customs clearance documents for cross-border battery shipping are more complex than those for ordinary goods. Three types of materials – “certification documents, license documents, and declaration documents” – must be prepared in advance to ensure completeness and consistency of information:

• List of Required Documents:

1. UN38.3 Test Report (original or stamped copy);
2. Dangerous Goods Transportation Identification Certificate (issued by an institution recognized by local customs; e.g., in China, issued by the “National Packaging Product Quality Inspection and Testing Center”);
3. Destination Country Import License Documents (e.g., U.S. DOT License, Japan METI Filing);
4. Commercial Invoice and Packing List (must indicate the battery’s UN number, energy, and quantity);
5. Dangerous Goods Declaration Form (IMDG Declaration Form for sea transportation, IATA Dangerous Goods Declaration Form for air transportation);

• Document Consistency Requirements:

The “battery model, quantity, and UN number” in all documents must be consistent. For example, if “lithium-ion batteries UN3480” marked on the commercial invoice is inconsistent with “UN3090” marked on the dangerous goods declaration form, customs will determine it as “false declaration” and detain the cargo.

(10) Consideration 10: Pay Attention to Battery Recycling Policies to Avoid “Illegal Disposal of Waste Batteries”

Some countries have strict requirements for the disposal of “waste batteries”. Enterprises must understand the destination country’s recycling rules